Prohibited

Since Russia’s invasion of Ukraine in February 2022, the European Union (“EU”) has continued to impose restrictive measures to sanction Russia’s actions. Regulation No.: 833/2014 The bill aims to restrict and prohibit the import and export of certain products originating from Russia and has therefore been amended several times.

Some of these changes are aimed at limiting Russia’s industrial capacity. For example, from June 3^roadIn 2022, it is prohibited to provide certain services directly or indirectly to the Russian government or legal persons, entities or organizations established in Russia. The fifth §1 Target Accounting services, business and management consulting services or Public Relations Services.

From October 6^dayIn 2022, following the 8^day The ban has been extended to other services as part of the sanctions package. Article 5n, paragraph 2,For example, Provide legal consulting services and IT consulting services.

December 18^dayIn 2023, Regulation (EU) No. 833/2014 was amended again following the adoption of the twelfth round of sanctions “packages”. The fifth Supplemented 2bThis section prohibits the sale, transfer, export or direct or indirect provision of Enterprise Management Software and industrial design and Manufacturing software listed in Annex XXXIX The ban covers updates and upgrades to Russian government or legal entities, as well as software in physical form (such as on a USB key) and intangible form (if stored in the cloud), according to the commission’s FAQ.

Business Management Refers to the system used “Represent and digitally control all processes that occur within a company”, including enterprise resource planning (ERP), customer relationship management (CRM), business intelligence (BI) or supply chain management (SCM).

Design and manufacturing software Includes softwareFor use in architecture, engineering, construction, manufacturing, media, education and entertainment, including” Software that supports Building Information Modeling (BIM), Computer-Aided Design (CAD), and Computer-Aided Manufacturing (CAM).

It must be emphasized that All typical components This appendix also covers the above mentioned suites. For example, regarding business management software, accounting software, fleet management, logistics and human resources.

With regard to the expiry date of Article 5n 2b, the prohibition to which this provision relates has come into force December 18^day2023However, the Commission granted an extension: the bans will come into force in March 20^day2024, For signed contracts Before December 19^day2023, or Necessary for the performance of ancillary contracts.

These prohibitions in Article 5n, paragraphs 1, 2 and 2b, apply only to Russian subsidiaries of EU groups As June 20^day2024From this date, the provision of these services requires authorization. However, it is important to remember that the Commission will sanction circumvention of sanctions. Therefore, the “due diligence” process.

Main article link: Council Regulation (EU) No 833/2014 of 31 July 2014 (consolidated version)

European Commission FAQs: Comprehensive FAQs on the implementation of Council Regulation No. 833/2014 and Council Regulation No. 269/2014

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